This analysis describes what Duolingo's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
The updated policy now discloses that audio collection for product improvement applies to all users across all platforms (iOS, Android, and web), whereas previously the policy stated audio was collected only from iOS users. Android and web users are now subject to audio collection for product improvement purposes. All users can opt out of audio sharing within app Settings.
View change record →The updated policy introduces a new Session Replay service that logs user activity alongside FullStory, capturing clicks, mouse movements, scrolling, typing, device information, navigation, and learning activity. Both services can be disabled using the Tracking toggle in app Settings, and both are automatically disabled for child users. The new Math Tutor feature shares audio with Apple for speech recognition and immediate deletion, but retains and shares text transcripts with AI vendors. For payment processing and fraud prevention, Duolingo may retain IP addresses beyond the standard 30-day period. You can disable both FullStory and Session Replay activity recording by toggling the Tracking setting within the app.
View change record →How other platforms handle this
Zoom may obtain and aggregate technical and other data about your and your End Users use of the Services and Software on a de-identified or anonymized basis...and Zoom may use the Aggregated Anonymous Data in accordance with applicable Law...
We process your data for necessary purposes as described in the main Policy, and for secondary purposes. We use both human and automated means to process your data.
Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities
"Duolingo may anonymize your personal information, and use this de-identified data for any purpose, such as better understanding learning trends and training artificial intelligence models.Excerpt from Duolingo's Privacy Policy
We read the privacy policies and terms of service of 38 AI platforms. Here is what they say about training, retention, arbitration, and liability.
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The clause states: “Duolingo may anonymize your personal information, and use this de-identified data for any purpose, such as better understanding learning trends and training artificial intelligence models.”
ConductAtlas has identified this type of provision across 273 platforms. See the full comparison.
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